Modern Slavery Policy

Modern slavery is a term used to encompass not only slavery but servitude, forced and compulsory labour, bonded and child labour and human trafficking.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015; whose purpose is to ensure companies & their supply chains are free from modern slavery and human trafficking by implementing systems and controls that are preventative in their application.

CODA is committed to ensuring that there is no modern slavery or human trafficking in any part of our business or our supply chains. We are committed to acting ethically and with integrity in all our business relationships and enforcing effective processes and controls to ensure slavery and human trafficking is not taking place anywhere is our supply chains.

ORGANISATIONAL STRUCTURE AND SUPPLY CHAINS

CODA currently operates in the following countries: England, Scotland, Wales & Ireland.

CODA is the only reporting entity offering our clients with a complete product and service package for design, build, delivery and furniture solutions.

Details of our supply chain can be requested by visiting our contacts page.

RESPONSIBILITY

Responsibility for CODA anti-slavery initiatives is predominantly that of the company director. This includes the development, implementation, and awareness of our anti-slavery initiatives.

External HR, health & safety, & legal Consultants will be engaged as required.

CODA understand the responsibility and need for risk assessments in respect of human rights by a process of annually reviewing the business activities of CODA and ensuring that due diligence has been conducted on any clients and/or suppliers that CODA may come into contact with.

TRAINING

To ensure our team has a good understanding of the risks of modern slavery and human trafficking in our business, supply chains and generally within the industry, CODA requires all staff to complete online training.

ASSOCIATED POLICIES

As part of our evolvement, CODA are currently undergoing the registration of ISO accreditation, in order for us to document we ensure the highest level of record keeping and document/procedure management, as well as making sure our systems remain enforced.

RECRUITMENT

CODA employ only the highest calibre of employee and as such undertake all relevant pre-employment checks prior to staff being employed. Our recruitment partners are aware of our standards and allow us to maintain the highest possible standards of employee conduct and ethical behaviour not only in our project delivery but managing our supply chain.

WHISTLEBLOWING

CODA is committed and actively encourages a culture of honesty, openness and accountability throughout the business. As part of this, we provide a confidential process for employees to report any concerns they may have about any aspect of our work or our supply chain, including abuse and neglect of vulnerable people.

DUE DILIGENCE

In order to mitigate the risk of human trafficking & slavery in the delivery of service and supply chain, CODA undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers.

This includes building long-standing relationships with suppliers and making clear our expectations of business partners and evaluating the modern slavery and human trafficking risks of each new supplier, invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

All suppliers are expected to submit CODA’s pre-qualification questionnaire annually and provide evidence of compliance with the principals of the Modern Slavery Act, regardless of the business’ size.

To ensure an understanding of the potential risks of modern slavery and human trafficking in delivering our services and managing our supply chain, annual refresher training is available for all CODA employees.

Where appropriate references to the Modern Slavery Act 2015 will be in our policies and procedures. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.

PERFORMANCE INDICATORS

CODA uses key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including requiring all relevant staff to have completed training on modern slavery.

This modern slavery and human trafficking statement will be regularly reviewed and updated as necessary. The company director endorses this policy statement and is fully committed to its implementation.

Efficient with communications and always candid about delivery times.

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